Afiniti Website & Portal Privacy Policy

Updated May 2, 2017
Effective June 2, 2017

This privacy policy covers Afiniti’s (“we,” “us,” or “our”) collection, use, and disclosure of information through the Afiniti website, Afiniti Portal, and Afiniti AIMS Portal (collectively, the “Sites”). To learn about how we collect, use, and disclose information in connection with the services that we provide to our clients, please visit the Afiniti Services Privacy Policy. If you have any questions about our Sites or this privacy policy, please contact us at privacy@afiniti.com.

By visiting our Sites and using the features made available to you on the Sites, you are agreeing to the terms of this privacy policy. Our Sites may include links to other websites whose privacy practices may differ from those of Afiniti. If you submit information to any of those third-party websites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.


Information Collection

Afiniti collects both Personal Information and Other Information from users of our Sites. For purposes of this privacy policy, “Personal Information” is information that we can directly associate with a specific person without additional information. “Other Information” is any information that is not Personal Information. For example, we may collect:

  • Personal Information about representatives of Afiniti’s enterprise clients. We collect Personal Information from representatives of Afiniti’s enterprise clients, such as:

    • When client employees are registered for Afiniti Portal access, in which case we may collect the employee’s first and last name, email address, and username and password; and
    • When client employees fill out and submit surveys through the Afiniti AIMS Portal, in which case we may collect any information that our clients’ employees voluntarily submit to us.
  • Personal Information about website visitors and prospective clients or partners. We collect Personal Information from website visitors and prospective clients or partners who contact us through our website. In this context, we may collect your first and last name, phone number, email address, and any other information that you voluntarily submit to us through our “Contact Us” form or other means of communication.
  • Personal Information about prospective employees. We collect information about prospective employees when they submit a job application form on our website. For example, we may collect an applicant’s first and last name, phone number, email address, city and country of residence, and any other Personal Information that the applicant voluntarily submits to us, such as information contained in a cover letter, resume, or curriculum vitae.
  • Other Information collected via passive collection and tracking technologies. Like most websites, in addition to the Personal Information described above, we also gather certain Other Information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our Sites (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, general location, and/or clickstream data. We and our third-party service providers may collect such information using the following technologies:

    • Server Logs. When you use the Sites, we automatically receive and record certain information from your computer (or other device) and your web browser. To collect such information, we may use server logs or applications that recognize your computer and gather information about its online activity.
    • Cookies and similar technologies. Afiniti and our service providers use cookies and similar technologies to analyze trends, administer the Sites, track users’ movements around the Sites, and gather information about our user base as a whole. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete existing cookies from your computer. However, if you choose to block or delete cookies, certain features of the Sites may not operate correctly.
    • Pixel tags. The Sites may collect information through a “pixel tag” (also known as a “clear gif” or “web beacon”). A pixel tag is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page to transmit information about your use of the Sites.

We partner with certain third parties to collect Other Information to engage in analytics, auditing, research, and reporting. These third parties may use logs or pixel tags, and they may set and access cookies on your computer or other device. In particular, the Sites use Google Analytics to help collect and analyze certain information for analytics purposes. You may opt out of the use of cookies by Google Analytics here. Please note that our Sites currently do not respond to browser Do Not Track signals.

We may combine Other Information with Personal Information, in which case we will treat the combined information as Personal Information. We also may combine the information that we collect on our Sites with additional information that we or third parties collect in other contexts—such as our communications with you via email or phone, or your customer service records. In those circumstances, we will treat the combined information in accordance with this privacy policy.


Information Use

Afiniti uses the information that it collects for a variety of purposes, including to:

  • Provide the services to our clients, administer user accounts, and respond to customer service requests;
  • Contact our clients or prospective clients and respond to requests for information about Afiniti;
  • Use survey information collected through the AIMS Portal to determine the optimal fit between our clients’ customers and representatives, as described in the Afiniti Services Privacy Policy;
  • Process and evaluate job applications that we receive from prospective employees;
  • Administer the Sites, conduct internal auditing, and troubleshoot technical or user issues on the Sites;
  • Count and recognize visitors and users of the Sites and analyze how individuals use our services;
  • Improve our existing products and services or create new products and services;
  • Generate and analyze trends in the aggregate; and
  • Comply with legal and/or regulatory requirements.

Information Disclosure

Afiniti may disclose the information that it collects to third parties for a variety of purposes, such as:

  • Affiliates. We may share Personal Information and Other Information with our corporate affiliates for the purposes described in this privacy policy.
  • Third-party service providers. We may use third-party service providers to help us provide our services, such as managing and maintaining our information systems. These service providers may collect and/or use your Personal Information or Other Information to assist us in carrying out the purposes discussed in this privacy policy. Transfers to subsequent third parties are covered by the provisions in this privacy policy regarding notice and choice and the service agreements with our clients.
  • Third-party plugins. Our website may integrate certain third-party plug-ins (such as a Facebook “like” button and Twitter “follow” button). Even if you do not click on these plug-ins, they may collect information about you, such as your IP address and the pages that you view. They also may set and/or access a cookie. These plugins are governed by the privacy policy of the company providing them.
  • Legal purposes. We may use or disclose your Personal Information or Other Information to third parties when we believe, in our sole discretion, that doing so is necessary:
    • To comply with applicable laws or a court order, subpoena, request from government or law enforcement, or other legal process;
    • To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
    • To establish, protect, or exercise our legal rights or defend against legal claims; or
    • To facilitate a merger, acquisition, or sale of all or a portion of Afiniti’s assets. You will be notified via email or a prominent notice on our website of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
  • De-identified or aggregated information. Afiniti also may share de-identified and aggregated information about users of our services, such as by publishing a report on trends in the usage of the Sites; and
  • With your consent. We may disclose your information to any other third party with your prior consent.

Afiniti is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. As noted below, Afiniti complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.


International Transfers, EU-U.S. Privacy Shield, and Swiss-U.S. Privacy Shield

We may transfer and process the information that we collect through our Sites to the United States or another country outside your country of residence. Afiniti also may subcontract the processing of your information to, or otherwise share your information with, affiliates or third parties in the United States or another country. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By accepting this privacy policy, using the Sites, or providing information to us, you expressly consent to such transfer and processing.

Afiniti complies with the EU–U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Afiniti has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Afiniti is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Afiniti may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.


Access and Choices

Upon request Afiniti will provide you with information about whether we hold any of your Personal Information. You may request access, correction, or deletion of your Personal Information by contacting us at privacy@afiniti.com. We will respond to these requests within a reasonable timeframe.


Data Retention

Afiniti will retain information for as long as reasonably necessary to accomplish the purposes described in this privacy policy. Afiniti also will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Security

The security of your information is important to us. We use commercially reasonable physical, technical, and administrative safeguards to protect your information against loss or unauthorized access, use, modification, or deletion. However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your Personal Information. If you have any questions about the security of your Personal Information, you may contact us at privacy@afiniti.com.


Changes to this Privacy Policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by means of a notice on this website prior to the change becoming effective. We encourage you to review this page periodically for the latest information on our privacy practices.


Contact Us

If you are a client and would like to update or delete your Afiniti Portal account, please contact us at support@afiniti.com. We will respond to your request within a reasonable timeframe. If you have questions regarding our privacy policies or practices, please contact us at privacy@afiniti.com. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

For all other inquiries, please visit our contact page or write to us at:

Privacy @ Afiniti
1700 Pennsylvania Avenue
Suite 560
Washington, DC 20006

TRUSTe Privacy Certification